Case Digest (G.R. No. 219062)
Facts:
PNOC Shipping and Transport Corporation v. Honorable Court of Appeals and Maria Efigenia Fishing Corporation, G.R. No. 107518, October 08, 1998, Supreme Court Third Division, Romero, J., writing for the Court.The dispute arose from a collision on September 21, 1977, between the M/V Maria Efigenia XV owned by private respondent Maria Efigenia Fishing Corporation and the tanker Petroparcel, then owned by Luzon Stevedoring Corporation (LSC). The Board of Marine Inquiry found the Petroparcel at fault. After demands on LSC failed, private respondent sued LSC and the Petroparcel captain in the Court of First Instance (CFI) of Caloocan, paying an initial docket fee of P1,252.00 and claiming P692,680.00 for lost nets, equipment and cargo.
While the case was pending, PNOC acquired the Petroparcel and sought substitution for LSC; private respondent filed amendments to plead additional damages including the vessel’s hull value (alleged at P800,000.00 less P200,000.00 insurance = P600,000.00), alleged inflationary increases, and unrealized profits. PNOC was later impleaded as defendant; the trial court issued a pre-trial order containing stipulated facts about the collision, transfer agreements between LSC and PNOC, and the Board’s finding.
At trial private respondent’s sole witness, general manager Edilberto del Rosario, testified and offered documentary price quotations and pro forma invoices dated mostly in January 1987 (Exhibits B–H) to prove replacement values; petitioner offered Lorenzo Lazaro as its only witness but produced no supplier quotations to rebut the exhibits. On November 18, 1989, the Regional Trial Court (RTC), Branch 121, Caloocan City, rendered judgment for private respondent awarding P6,438,048.00 as actual damages, P50,000.00 attorneys’ fees and costs, and dismissed certain counterclaims for lack of jurisdiction.
Petitioner moved for reconsideration arguing, inter alia, lack of jurisdiction because private respondent had not paid a docket fee corresponding to the increased claim, and that the award exceeded the amount pleaded and was unsupported by competent evidence. The RTC denied reconsideration on January 25, 1990. The Court of Appeals affirmed the RTC decision in toto on October 14, 1992 (CA-G.R. CV No. 26680), deferring to the trial court’s discretion to admit the price quotations and finding them uncontroverted; it also applied Sun Insurance Ltd. v. Asuncion regarding enforcement of unpaid docket fees as liens on judgment.
Petitioner elevated the case t...(Subscriber-Only)
Issues:
- Did the trial court acquire jurisdiction over the amended complaint despite private respondent's failure to pay the docket fee corresponding to its increased claim?
- Were the documentary price quotations and related exhibits competent evidence to sustain the RTC’s award of P6,438,048.00 as actual damages?
- If the award of actual damages is unsupported, wh...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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